A conversation with Provision
🎧 Listen to the full interview in the audio player below, or read on for our key takeaways from their conversation.
How can produce suppliers and retailers meet the upcoming FSMA 204 traceability requirements while streamlining their operations?
The Food Safety Modernization Act (FSMA) Section 204 will bring some critical changes to the produce industry. With compliance deadlines approaching, growers, packers, and retailers are working to implement digital traceability solutions. These solutions are intended to not only meet regulatory requirements, but also enhance food safety and supply chain transparency.
To answer the above question, our very own Frederic (Fritz) Clulow, GM of the Americas at Kezzler, sat down with Kevin Davies, CRO at Provision, to discuss how the industry is preparing for FSMA 204.
They explore the role of digital solutions in overcoming common compliance hurdles, as well as:
- The biggest challenges growers and retailers face in meeting FSMA 204 compliance
- How digitization and data-sharing streamline traceability
- Why pack houses are a critical piece of the compliance puzzle
- How interoperability between solutions like Provision and Kezzler helps unify traceability across supply chains
The full transcription of the interview can be found at the bottom of the article.
The compliance challenge: FSMA 204 and the produce supply chain
FSMA 204 mandates end-to-end traceability and requires detailed, standardized recordkeeping for high-risk foods, but many growers, packers, and retailers are still figuring out how to comply.
Why is this so difficult?
- Data capture and standardization: The industry lacks a common approach to recording and sharing traceability data.
- Pen-and-paper workflows: Many growers still rely on manual recordkeeping, making it difficult to track and share data in real-time.
- Diverse and fragmented operations: A single supply chain often involves multiple tools and systems that don’t communicate with each other.
“When we see some of the clients that we work with today who have hundreds of growing operations under centralized packhouse umbrellas, really, I think that the data sharing and having unified data standards between those operations could be the greatest complexity that these operations face as they move into implementing solutions this year.”
– Kevin Davies, Provision
One of the biggest hurdles is ensuring pack houses—which play a pivotal role in consolidating traceability data—are fully equipped to meet compliance standards.
“Where we really see as the area for focus in the produce supply chain is the pack houses. A lot of the pack houses that we’ve seen haven’t yet necessarily started their implementation for FSMA 204. But they’re really a key point of custody in the traceability chain because they’re generating the TLC.”
– Kevin Davies, Provision
Frederic echoed this challenge, noting that even large enterprises struggle with standardization.
“The real challenge with FSMA 204 is that there is no single approach that works across the board. A retailer, for example, might get a thousand shipments from different suppliers, and every single one might have slightly different data formats. It’s hard to build a system around that unless you have true interoperability.”
– Frederic Clulow, Kezzler
The role of digitization and data management in compliance
Moving from paper-based records to digital systems is essential for FSMA 204 compliance, but the process is not always straightforward.
Kevin explained how Provision helps growers, packers, and shippers digitize compliance data and integrate FSMA 204 compliance and traceability into their existing food safety and sustainability programs.
“Many of them are already doing harvest logs for Primus GFS or Global Gap, or whatever it may be for their food safety program. So really, it’s just a question of, ‘How can you integrate FDA-required key data elements into existing records so that you have the cleanest possible execution, effectively unifying traceability with food safety and sustainability requirements?’’”
– Kevin Davies, Provision
Why is digitization critical?
- Reduces manual errors in data entry
- Enables real-time record-keeping for audits and compliance
- Creates a single source of truth for all traceability data
By transitioning from manual data collection to automated, digital systems, companies can reduce manual errors in data entry, improve compliance efficiency with real-time recordkeeping, and enhance food safety transparency with a single source of truth for all traceability data.
“Digitization is what makes compliance not just easier but also more valuable. If companies can leverage their FSMA 204 compliance data for operational improvements, that’s a win-win.”
– Frederic Clulow, Kezzler
Why collaboration and interoperability matter: Kezzler and Provision
No single platform can fully handle FSMA 204 compliance alone. Traceability requires multiple systems working together, which is why the partnership between Provision and Kezzler is so valuable. Provision and Kezzler’s solutions work together to unify data across multiple systems and stakeholders.
By integrating Kezzler’s traceability platform with Provision’s compliance tools, supply chain participants can:
- Ensure seamless data-sharing between suppliers, packers, and retailers
- Enable API-based interoperability instead of relying on outdated, batch-based EDI systems
- Unify data across fragmented operations to provide end-to-end traceability
“Kezzler, we think, is a best-in-class platform to unify data for many platforms. I think that it’s important to think downstream that there will be many traceability tools that need to connect together. You never see one tool that’s used throughout the chain. Even within one operation, you might see different tools used for receiving the transformation. So I think that having the ability to connect the API to a platform like Kezzler to get a single view can be a critical way to combine data across a network into kind of one easy place to conduct a trace back.”
– Kevin Davies, Provision
It’s perhaps redundant, but crucial to keep stressing the importance of interoperability—the industry is moving away from outdated batch processing methods.
“We’re not in a world where EDI and batch data transfers can keep up with the speed of modern supply chains. Real-time, API-driven traceability is what companies need to actually make FSMA compliance functional.”
– Frederic Clulow, Kezzler
Final takeaways and next steps
As FSMA 204 deadlines approach, companies in the produce supply chain need to take action by:
- Standardizing data collection: Implementing consistent data formats across suppliers and packers.
- Digitizing compliance efforts: Moving away from manual recordkeeping to integrated software solutions.
- Ensuring interoperability: Partnering with solutions that seamlessly connect through APIs to provide a holistic traceability view.
📢 Want to learn more? Listen to the full conversation.
Chapters
00:00:00 Introduction and overview of FSMA 204
00:00:43 Kevin Davies introduces Provision
00:02:12 Why Kezzler partners with Provision
00:02:59 Challenges in the produce supply chain
00:06:21 Digitization and compliance solutions
00:11:34 Tools and strategies for growers
00:18:10 Data sharing and interoperability
00:23:45 Focus on pack houses
00:25:46 Key success criteria for traceability programs
00:28:27 ERPs vs. specialized traceability tools
00:30:31 Conclusion and future collaboration

